Informationen zum Autor Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., youngest full-time law professor in the United States when appointed (Wayne State University), age 23; member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer - CCH, and Thomson - RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia. Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH). Klappentext An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businessesA comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders.Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad.* Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries* Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region* Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the lawA complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad. Zusammenfassung An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. Inhaltsverzeichnis Preface xxi PART ONE: COUNTRY-BY-COUNTRY ANALYSIS 1 Chapter 1 Introduction 3 Part One: Country-by-Country Analysis 3 Part Two: Advanced Applications 4 Chapter 2 Australia's Risk Assessment Transfer Pricing Approach 7 Introductory Issues 8 Transfer Pricing Reviews 8 Documentation Requirements 10 Preparation of the Documentation File 11 Applying the Arm's Length Principle 13 Simplified Approach to Doing a Benchmarking Study 13 Four Steps for Testing International Transfer Prices 14 Decision Tree 16 How the ATO...

Autorentext

Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., youngest full-time law professor in the United States when appointed (Wayne State University), age 23; member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer - CCH, and Thomson - RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia.

Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH).

Klappentext

An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. * Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries * Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region * Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad.

Inhalt

Preface xxi

PART ONE: COUNTRY-BY-COUNTRY ANALYSIS 1

Chapter 1 Introduction 3

Part One: Country-by-Country Analysis 3

Part Two: Advanced Applications 4

Chapter 2 Australia's Risk Assessment Transfer Pricing Approach 7

Introductory Issues 8

Transfer Pricing Reviews 8

Documentation Requirements 10

Preparation of the Documentation File 11

Applying the Arm's Length Principle 13

Simplified Approach to Doing a Benchmarking Study 13

Four Steps for Testing International Transfer Prices 14

Decision Tree 16

How the ATO Scores Risk 16

Scoring the Three Levels 17

Score Graph 18

Outcome of Transfer Pricing Review or Audit 19

Audits Taking Place in Low-Risk Situations 20

Transfer Pricing Review Process 20

Categorizing the Results of the Transfer Pricing Review 21

How the Australian Transfer Pricing Audit Procedure Works 22

Australia's Four-Step Process for Businesses 22

Chapter 3 Profit Attribution for a Dependent

Agent's Permanent Establishment in Australia 25

Permanent Establishment Concepts in Australia 26

Profit Attribution Concepts in Australia 26

The ATO's Operational Approach 26

Determining Functional Analysis for a Permanent Establishment 27

Comparative Analysis fo…